The assessment will based on the methodology defined by the Government of Ontario Ministry of Government Services (MGS) Privacy Impact Assessment Guidelines which requires that a PIA be completed on any initiative that involves a substantive change to the collection, use or disclosure of personal information. This includes, for example, the creation or modification of databases, identification or authentication schemes; changes to program delivery mechanisms that may modify existing masking of information, or the use of 'smart cards'. The Guidelines also set out a framework for PIAs.